Can Someone Inherit From a Person They Killed? The Riggs Case

A will identifies someone as a beneficiary. That person then kills the person who made the will in order to receive the property sooner. Should the written gift still be carried out?

That question was at the center of Riggs v. Palmer, 115 N.Y. 506 (1889). The case came from New York and is a historic example of the issue commonly associated with the slayer rule.

What happened in Riggs?

Francis Palmer’s will left much of his estate to his grandson, Elmer. Elmer poisoned his grandfather to prevent a change to the will and obtain the property.

The New York Court of Appeals majority refused to allow Elmer to take the gift. It reasoned that the inheritance statutes should not be applied to allow someone to obtain property through his own crime.

The dissent focused on the limits of the court’s authority to add consequences not stated in the governing statutes. The disagreement concerned legal interpretation, not whether the killing was acceptable.

What is the Iowa rule?

Iowa’s answer comes from its own law, including section 633.535. A person who intentionally and unjustifiably causes or procures another’s death is barred from receiving property or benefits by reason of that death. The statute directs the affected property to pass as though that person had died first.

The section addresses more than gifts under a will. It also covers interests such as survivorship rights and life-insurance benefits. The wording and the particular asset still need to be examined.

Does there have to be a criminal conviction?

Section 633.536 provides for a separate civil determination under a preponderance-of-the-evidence standard. It also gives specified murder or voluntary-manslaughter convictions a conclusive effect for these purposes and regulates the timing of the civil proceeding.

This means a criminal case and an inheritance case are related, but they are not necessarily the same proceeding with the same burden of proof. An accusation alone does not answer the civil question.

Why is the distinction important?

Riggs can introduce the principle, but citing a famous case from another state is not a substitute for identifying Iowa’s governing provisions. A careful explanation should separate the historic dispute from the law being applied now.

The broader lesson is that a beneficiary designation or a will is part of the analysis. Other legal rules can affect whether the named person is entitled to receive the property. That is why the documents and the applicable law need to be considered together.

Tyler ThompsonAuthor